FSHN07-07

Hazard Analysis Critical Control Points (HACCP)

Principle 6: Establish Verification Procedures1
Ronald H. Schmidt and Debby L. Newslow2

HACCP verification is defined as those activities, other than
monitoring, that establish the validity of the HACCP plan
and ensure that the HACCP system is operating according
to the plan. Verification is done to determine:
that the HACCP plan is being implemented properly;
that practices used are consistent with the HACCP plan;
that the HACCP system is working to control significant
hazards; and
whether modifications of the HACCP plan are required
to reduce the risk of recurrence of deviations.
I. Elements of HACCP Verification
The primary components of verification are:
Critical Control Point (CCP) verification;
HACCP system verification; and
Validation.
A. Critical Control Point Verification
By definition, Critical Control Points (CCPs) are the
backbone of the HACCP plan with regard to controlling
food safety hazards. Therefore, it is important that all
activities and procedures are verified and accurate. CCP
verification involves the following activities:
1. Verification of CCPs
Verification involves confirming that CCPs were properly
selected and/or whether other processing steps would be
more appropriately defined as CCPs.
2. Verification of Critical Limits
(CLs), CCP Monitoring, and Corrective
Actions
All CCP-related activities necessary to ensure compliance
with the HACCP plan must be verified. This includes
establishing that all the responsible individuals defined
in the HACCP plan are performing in accordance with
the plan, that all monitoring procedures are appropriate
and being conducted at the appropriate frequency, and
that the corrective action plan is appropriate and being
implemented as described in the plan.
It may be desirable or necessary to check the adequacy of
monitoring by performing additional sampling and testing.
Such testing provides information on the adequacy of
monitoring procedures by having another person perform
the monitoring. In addition, independent testing may be

This document is FSHN 07-07, one of a series of the Department of Food Science and Human Nutrition, Florida Coopera-
tive Extension Service, IFAS, University of Florida. First published August 2007. February 2013.

1. Please visit the EDIS website at http://edis.ifas.ufl.edu.

2. Ronald H. Schmidt, professor, Food Science and Human Nutrition Department, Cooperative Extension Service, Institute of Food and Agricultural
Sciences, University of Florida, Gainesville, FL 32611, and Debby Newslow, Executive Director, D.L. Newslow and Associates, Inc.

The Institute of Food and Agricultural Sciences (IFAS) is an Equal Opportunity Institution authorized to provide research, educational information and other services only to
individuals and institutions that function with non-discrimination with respect to race, creed, color, religion, age, disability, sex, sexual orientation, marital status, national
origin, political opinions or affiliations. U.S. Department of Agriculture, Cooperative Extension Service, University of Florida, IFAS, Florida A&M University Cooperative
Extension Program, and Boards of County Commissioners Cooperating. Nick T. Place , Dean
used to provide validation that the CCP is, in fact, control-
ling the identified hazard(s).
3. Calibration
Adequate monitoring of CCPs is dependent upon accurate
and precise measurements of the parameters (e.g., tempera-
ture, pressure, pH, other parameters) to ensure that Critical
Limits (CLs) are met. Thus, it is important that properly
calibrated equipment is used to make these measurements.
The HACCP plan must describe instrument calibration
procedures, note the frequency of calibration, list the
individual(s) responsible, and describe the documentation
records to be used.
4. CCP Records Review
A significant verification activity is the review of all CCP
records, including monitoring records, corrective action
records, calibration records, and any other records related
to the CCPs. Records are verified to ensure that all records
are prepared and implemented according to procedures
described in the HACCP plan. This includes evaluation to
ensure that monitoring is being performed using appropri-
ate procedures and frequency, that responsible individuals
are appropriately identified, and that the documents are
properly signed. In addition, verification provides assur-
ance that all deviations of CLs are appropriately identified
and recorded, that corrective actions are taken for every
deviation and are conducted according to the HACCP Plan,
and all decisions are justified.
B. HACCP System Verification
While the HACCP plan is the written document which
delineates procedures, the HACCP system is the implemen-
tation of this plan. In CCP verification, we are examining
the HACCP plan: specifically, those activities that involve
the CCPs or backbone of the plan. HACCP system
verification involves those activities that go beyond the
written plan and, thus, apply to its implementation. Typical
HACCP system verification includes thorough review of the
following:
1. Preliminary Steps
Verification of the HACCP preliminary steps includes a
thorough evaluation as to whether:
the HACCP team is adequate and functioning in ac-
cordance with the plan;
all products covered by the plan are properly defined as to
composition, processing, and intended use; and
the flow diagram is still accurate and adequately describes
the steps in the processing system.
2. Prerequisite Programs
Verification of all prerequisite programs (PPs) included in
the HACCP plan must include, at a minimum, an annual
review of the written standard operating procedures
(SOPs) and other programs, as well as auditing of records
and documentation proving that these procedures and
programs are implemented and operating in accordance
with the plan. All instruments for detection or measure-
ment shall be calibrated (as described for CCP verification)
according to an appropriate procedure and frequency.
3. Hazard Analysis
Verification determines whether the procedures used in
the hazard analysis are appropriate and implemented as
described in the HACCP plan, and whether the sources of
information were appropriate and used appropriately. In
addition, the hazard analysis must also be validated (see
discussion below).
4. HACCP System Records Review
While those records involved with CCPs are discussed
above, HACCP system verification involves examining all
other documentation and records as to accuracy, comple-
tion, and implementation. This includes examining the
HACCP plan itself, prerequisite program records, written
summaries and narratives for activities within the plan,
backup justification and related literature, verification and
calibration records, consumer complaint records, and any
other appropriate documentation showing that the HACCP
system is being implemented appropriately.
C. Validation
HACCP validation is defined as that element of verification
focused on collecting and evaluating scientific and technical
information to determine whether the HACCP plan, when
properly implemented, will effectively control the identified
food hazards. The verification activities described above
are done to determine whether the HACCP plan is being
implement as required (i.e, whether you are doing what you
said you were going to do). Validation, however, is done to
determine whether the HACCP plan is working to control
the significant hazards (i.e., whether you are doing the right
things). Validation involves scientific and technical review
of the rationale behind each part of the HACCP plan, from
hazard analysis through each CCP verification strategy.
More specifically, validation is done to determine that the:
Hazard analysis is appropriate and realistic;
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 HACCP plan is controlling hazards; and
HACCP plan is based upon current science.
Validation involves re-examining the hazard analysis, CCPs,
CLs, monitoring activities, and other aspects of the HACCP
plan to assure that the appropriate hazards are identified
and that they are being controlled. This may involve either:
Evaluation of scientific literature;
External or third-party consultation and validation of the
processing system; or
Internal or in-plant observations or experiments.
II. Procedural Aspects of HACCP
Verification
HACCP verification must follow a well-conceived, written
plan, with all activities clearly defined. This plan must
clearly identify the individuals responsible, the procedures
to be used, and the frequency of verification. Those food
processing systems which fall under HACCP regulations
should be aware of and follow regulatory requirements
for verification procedures, frequency, and completion of
records review.
A. Responsible Individuals
The HACCP team should perform all verification activities.
In addition, it may be desirable to bring in a third-party
HACCP auditor to do the verification. In some instances,
third-party verification is required by customers. If under
a regulatory HACCP program, verification is also done
under regulatory audits. While it is not recommended that
a regulatory audit be the only verification activity, these
audits provide useful information.
B. Verification Procedures
HACCP verification must be done using scientifically
sound procedures. Care should be taken when identifying,
developing, and implementing these procedures.
C. Frequency of Verification
It is generally recommended (or required under HACCP
regulations) that HACCP verification be done at least annu-
ally, and whenever there is a significant change in the food
processing and handling system. However, many HACCP
verification activities (e.g., equipment calibration) may
require more frequent verification. The frequency should be
determined by the HACCP team after careful consideration
and must be sufficient to ensure and document that the
HACCP plan is being implemented properly.
HACCP validation is usually done initially and then
annually thereafter, and whenever significant changes occur
or factors warrant validation (e.g., new scientific data on
hazards and control measures, foodborne illness outbreaks,
recurring deviations). In addition, corrective actions may
require revalidation. Based upon validation, the HACCP
team shall determine if any changes in the hazard analysis
or HACCP plan are required.
III. Verification Forms
While CCP verification may be generally summarized in
the HACCP Plan Form as shown in Table 1, the HACCP
team should develop forms to document all verification
activities. A written discussion of verification activities
should also be included. Examples of a verification form
and validation form are shown in Table 2 and Table 3,
respectively.
References
Codex Alimentarius. (2003). Hazard analysis and critical
control point (HACCP) system and guidelines for its ap-
plication. ANNEX to Recommended International Code
of Practice/General Principles of Food Hygiene. CAC/
RCP 1-1969, Rev 4. FAO/WHO Codex Alimentarius
Commission.
Food and Drug Administration Center for Food Safety
and Applied Nutrition. (1995). Procedures for the safety
and sanitary processing and importing of fish and fishery
products. Final Rule, 18 Dec. 1995. Federal Register, 60,
65095-65202.
Food and Drug Administration Center for Food Safety and
Applied Nutrition. (1995). Fish and fishery products. Code
of Federal Regulations, Title 21, Part 123.
Food and Drug Administration Center for Food Safety
and Applied Nutrition. (2001). Hazard analysis and critical
control point (HAACP) (sic) procedures for the safe and
sanitary processing and importing of juice. Final Rule, 19
Jan. 2001. Federal Register, 66, 6137-6202.
Food and Drug Administration Center for Food Safety
and Applied Nutrition. (2001). Hazard analysis and critical
control point (HACCP) systems. Code of Federal Regula-
tions, Title 21, Part 120.
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Food Safety and Inspection Service. (1996). Pathogen
reduction; hazard analysis and critical control point
(HACCP) systems. Final Rule, 25 July 1996. Federal Regis-
ter, 61, 38856-38906.
Food Safety and Inspection Service. (1996). Hazard analysis
and critical control point (HACCP) systems. Code of Federal
Regulations, Title 9, Part 417.
International Dairy Foods Association (IDFA). (2006).
Advanced HACCP Short Course for Dairy and Juice Products
Course Manual. IDFA, Washington, DC.
National Advisory Committee on Microbiological Criteria
for Foods (NACMCF). (1998). Hazard analysis and critical
control point principles and application guidelines. Journal
of Food Protection, 61, 762.
Scott, V. N., and Stevenson, K. E. (2006). HACCP: A
systematic approach to food safety. Washington, D.C.: Food
Products Association.
and Agricultural Sciences, University of Florida. Retrieved
August 1, 2007, from http://edis.ifas.ufl.edu/fs140
Schmidt, R. H., and Newslow, D. L. (2007). Hazard analysis
critical control points (HACCP) Principle 3: Establish
Critical Limits and Principle 4: Monitoring Critical Control
Points (CCPs) (FSHN0705). Gainesville: Department of
Food Science and Human Nutrition, Florida Cooperative
Extension Service, Institute of Food and Agricultural
Sciences, University of Florida. Retrieved August 15, 2007,
from http://edis.ifas.ufl.edu/fs141
Schmidt, R. H., and Newslow, D. L. (2007). Hazard analysis
critical control points (HACCP) Principle 5: Establish
Corrective Actions (FSHN0706). Gainesville: Department of
Food Science and Human Nutrition, Florida Cooperative
Extension Service, Institute of Food and Agricultural
Sciences, University of Florida. Retrieved August 30, 2007,
from http://edis.ifas.ufl.edu/fs142

Schmidt, R. H., and Newslow, D. L. (2007). Hazard analysis

critical control points (HACCP) Getting started, prelimi-
nary steps (FSHN0701). Gainesville: Department of Food
Science and Human Nutrition, Florida Cooperative Exten-
sion Service, Institute of Food and Agricultural Sciences,
University of Florida. Retrieved July 24, 2007, from http://
edis.ifas.ufl.edu/fs137

Schmidt, R. H., and Newslow, D. L. (2007). Hazard analysis

critical control points (HACCP) Prerequisite programs
(FSHN0702). Gainesville: Department of Food Science and
Human Nutrition, Florida Cooperative Extension Service,
Institute of Food and Agricultural Sciences, University of
Florida. Retrieved July 24, 2007, from http://edis.ifas.ufl.
edu/fs138

Schmidt, R. H., and Newslow, D. L. (2007). Hazard analysis

critical control points (HACCP) Principle 1: Conduct a
Hazard Analysis (FSHN0703). Gainesville: Department of
Food Science and Human Nutritions, Florida Cooperative
Extension Service, Institute of Food and Agricultural
Sciences, University of Florida. Retrieved August 1, 2007,
from http://edis.ifas.ufl.edu/fs139

Schmidt, R. H., and Newslow, D. L. (2007). Hazard analysis

critical control points (HACCP) Principle 2: Determine
Critical Control Points (CCPs) (FSHN0704). Gainesville:
Department of Food Science and Human Nutrition,
Florida Cooperative Extension Service, Institute of Food

4
 Table 1. HACCP Plan Form
HACCP Plan Form
Critical Hazard(s) Critical Monitoring Corrective Verification Record-
Control Limits for What How Frequency Who Actions Activities
Point (CCP)
CCP#1 Vegetative 161 F for 15 Temperature (F) Check and Every 2 hours Pasteurizer Manually divert Thermometer
Pathogens1 sec. sign off on Operator flow; Calibration - per
continuous Isolate affected Past. Milk Ord.
chart recorder product;Request (PMO) procedures.
evaluation by Pressure diff.
QA;Calibrate checks;Equipment
and adjust as calibration;Seal
necessary;Follow
CorrectiveAction
Plan for
disposition and
documentation

Table 2. Example of a HACCP Verification Form

HACCP VErIfICAtIon
date of specific Activity being Verified summary of Verification name of Verifier Expected outcome and Actions
Verification (hazard Activities frequency of Verification taken
analysis, CCPs,corrective actions, Activity (asdefined inHACCP
equipment, etc.) plan)

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 Table 3. Example of a HACCP Validation Form
HACCP VALIDATION
Date of Summary of Validation Activities Name of Expected Outcome and Actions
Validation Validator Frequency of Validation Taken
Activity(as defined inHACCP
plan)